The Illinois Appellate Court found a trial court's supplemental instruction to a deadlocked jury to be reversible error. The Court noted that although amplification or clarification of IPI instructions is permitted in limited circumstances where the IPI instruction is inadequate, the supplemental instruction in this case impermissibly pressured the jury to return a verdict. In reversing, the Court cited the instruction's emphasis on the time and expense invested by the parties in the original trial, the trial court's comment regarding the rarity of hung juries, and the trial court's intimation that failure to reach a verdict would deprive another case of the opportunity to be heard. Preston ex rel. Preston v. Simmons, 321 Ill.App.3d 789, 747 N.E.2d 1059, 254 Ill.Dec. 647 (1st Dist. 2001).
